Page 1 GAO-14-79R Nuclear Weapons

441 G St. N.W.

Washington, DC 20548

October 25, 2013

Congressional Committees

Nuclear Weapons: Information on Safety Concerns with the Uranium Processing Facility

The Y-12 National Security Complex in Oak Ridge, Tennessee, is the National Nuclear Security 

Administration’s (NNSA) site for conducting enriched uranium activities, producing uraniumrelated components for nuclear warheads and bombs, and processing nuclear fuel for the U.S. 

Navy.1

 NNSA is a separately organized agency within the Department of Energy (DOE). 

According to NNSA, the Y-12 plant’s current enriched uranium operations, which are conducted 

in four separate buildings, have key shortcomings including (1) an inefficient workflow; (2) 

continually rising operations and maintenance costs due to facility age; and (3) processes that 

could expose workers to radiological contamination, among other things. To address these 

issues, in 2004, NNSA decided to construct a new Uranium Processing Facility (UPF).2

• consist of a single, consolidated facility less than half the size of existing facilities; 

 

According to NNSA, the UPF will 

• reduce costs by using modern processing equipment; and 

• incorporate features to increase worker protection and environmental health and safety. 

The work carried out at several of DOE’s defense nuclear facilities involves dangerous nuclear 

materials and hazardous chemicals.3 For example, the UPF will process highly enriched 

uranium as well as beryllium, a hazardous metal essential for nuclear operations. Contractors 

are responsible for safely designing, constructing, and operating DOE’s defense nuclear 

facilities. DOE’s oversight of how these facilities’ safety systems are designed and operated is 

critical to ensuring the health and safety of workers, the public, and the environment.

4

 

1

NNSA owns the buildings, equipment, and the components produced at the Y-12 plant, but the site is operated 

under contract to NNSA by Babcock & Wilcox Technical Services Y-12, LLC (B&W), a partnership of the Babcock & 

Wilcox Company and Bechtel Corporation. 

 To assess 

2

B&W is the contractor managing the UPF design and has subcontracted portions of the design work to four other 

contractors.

3

DOE’s defense nuclear facilities are located at 13 sites, including 7 NNSA sites.

4

We have previously reported on challenges with DOE’s safety oversight. See GAO, Hanford Waste Treatment Plant: 

DOE Needs to Take Action to Resolve Technical and Management Challenges, GAO-13-38 (Washington, D.C.: Dec. 

19, 2012) and GAO, Modernizing the Nuclear Security Enterprise: Observations on DOE’s and NNSA’s Efforts to 

Enhance Oversight of Security, Safety, and Project and Contract Management, GAO-13-482T (Washington, D.C.: 

Mar. 13, 2013). 
Page 2 GAO-14-79R Nuclear Weapons

safety conditions at DOE’s defense nuclear facilities, Congress created the Defense Nuclear 

Facilities Safety Board (Safety Board)—an independent executive branch agency—in 1988. The 

Safety Board has broad oversight responsibilities regarding these facilities but does not have 

the authority of a regulator.5

At the request of the Senate Appropriations Committee, Subcommittee on Energy and Water 

Development and in accordance with the Fiscal Year 2013 National Defense Authorization Act, 

GAO is required to submit quarterly reports on the UPF.6 Our first report was issued in July 

2013 and found that (1) key assumptions contained in multiple cost estimates proved to be 

inaccurate and were the primary factors that contributed to the UPF’s cost increase from $1.1 

billion in 2004 to $6.5 billion in 2012, and (2) the UPF contractor did not adequately manage and 

integrate the design work subcontracted to four other contractors and therefore the UPF’s roof 

will have to be raised 13 feet to ensure the processing equipment would fit into the facility, which 

resulted in approximately $540 million in additional costs.

7

To do this work, we reviewed key DOE management orders and standards that establish project 

management and safety requirements for constructing new nuclear facilities. In addition, we 

reviewed UPF safety-related documents prepared by DOE, NNSA, and the UPF contractor as 

well as multiple safety assessments of the UPF conducted by the Safety Board. We interviewed 

UPF contractor representatives responsible for developing key safety documents as well as 

NNSA officials who oversee this process. In addition, we visited the Y-12 plant and received 

safety-related briefings from NNSA and contractor officials. We also interviewed and received 

briefings from Safety Board staff responsible for conducting oversight of the UPF. 

Based on discussions and 

agreement with your offices, our objective for this second report was to identify the concerns, if 

any, that the Safety Board has raised with the UPF and the actions, if any, NNSA has taken to 

address those concerns. 

We conducted this performance audit from April 2013 to October 2013 in accordance with 

generally accepted government auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based on our audit objectives.

Background

The Safety Board exercises broad oversight over DOE facilities. Specifically, the Safety Board 

• reviews DOE’s safety and design documentation to ensure that DOE is complying with 

its own requirements and processes for integrating safety into the design process;

 

5

The Safety Board consists of five members appointed by the President and confirmed by the Senate and is 

supported by approximately 100 technical, legal, and administrative staff. 

6

The National Defense Authorization Act for Fiscal Year 2013 renamed UPF as the Uranium Capabilities 

Replacement Project. NNSA uses the new nomenclature in its fiscal year 2014 budget request. 

7

GAO, Nuclear Weapons: Factors Leading to Cost Increases with the Uranium Processing Facility, GAO-13-686R

(Washington, D.C.: July 12, 2013).
Page 3 GAO-14-79R Nuclear Weapons

• issues "project letters" to DOE at major project milestones to document the results of 

these reviews and communicate significant safety issues; and

• holds occasional public hearings to address concerns about DOE’s safety practices, 

including an October 2012 hearing on the UPF in Knoxville, Tennessee.

In 1990, we first designated DOE program management as an area at high risk of fraud, waste, 

abuse, and mismanagement.8 In January 2009, to recognize the progress made at DOE’s Office 

of Science, we narrowed the focus of the high-risk designation to two DOE program elements, 

NNSA and the Office of Environmental Management.9 In February 2013 we issued our most 

recent high-risk update, in which we narrowed this focus to major projects (i.e., projects over 

$750 million) at NNSA and the Office of Environmental Management.10 DOE has taken some 

steps to address our concerns, including developing an order in 2010 that defines DOE’s project 

management principles and process for executing a capital asset construction project.

11

• CD 0: Approve a mission-related need.

 NNSA 

is required to manage the UPF in accordance with this order. The project management process 

defined in Order 413.3B requires DOE projects to go through five management reviews and 

approvals, called “critical decisions” (CD), as they move forward from project planning and 

design to construction to operation. The CDs are: 

• CD 1: Approve an approach to meet a mission need and a preliminary cost estimate. 

• CD 2: Approve the project’s cost, schedule and scope targets. 

• CD 3: Approve the start of construction. 

• CD 4: Approve the start of operations. 

In June 2012, the Deputy Secretary of Energy reaffirmed CD 1 for the UPF and approved a 

phased approach to the project, which will defer significant portions of the facility’s original 

scope. This deferral was due, in part, to the project’s increased cost estimate and to accelerate 

the completion of the highest priority scope. Table 1 shows the UPF’s phases, scope of work, 

cost estimate as of June 2012, and key project dates.

 

8

GAO, Government Financial Vulnerability: 14 Areas Needing Special Review, GAO/OCG-90-1 (Washington, D.C.: 

Jan. 23, 1990). We update our high-risk list every 2 years. 

9

GAO, High-Risk Series: An Update, GAO-09-271 (Washington, D.C.: January 2009). 

10GAO, High-Risk Series: An Update, GAO-13-283 (Washington, D.C.: February 2013). 

11U.S. Department of Energy, Program and Project Management for the Acquisition of Capital Assets, DOE O 413.3B 

(Washington, D.C.: Nov. 29, 2010). 
Page 4 GAO-14-79R Nuclear Weapons

Table 1: Uranium Processing Facility (UPF) Phases, Scope of Work, Cost Estimate as of 

June 2012, and Project Dates 

Phase Scope of work Cost estimate as of June 

2012 

Project dates

Phase I UPF building exterior, all support 

systems, Building 9212 capabilities 

(uranium purification and casting)

$4.2 to $6.5 billion CD 2 expected in 2015a

CD 3 expected in 2015

CD 4 expected in 2025

Phase II Building 9215 (machining) and 

Building 9998 capabilities (product 

certification) 

NNSA has not established a 

cost estimate

CD 4 expected from 

2030 and 2036

Phase 

III

Building 9204-2E capabilities 

(assembly and dismantlement) 

NNSA has not established a 

cost estimate 

CD 4 expected from 

2030 and 2036 

Source: NNSA. 

a The project management process defined in DOE Order 413.3B requires DOE projects to go through five 

management reviews and approvals, called “critical decisions” (CD), as they move forward from project planning and 

design to construction to operation.

Key interim safety documents are to be completed by the contractor and approved by NNSA 

prior to CD 1, 2, and 3 milestones, while a final safety document is to be completed and 

approved prior to CD 4. According to Order 413.3B, these interim and final documents are to 

identify how the UPF’s nuclear material and hazardous chemicals will be handled, the potential 

accidents and hazards associated with the facility’s operations, and the controls employed to 

mitigate or prevent their impact on workers and the public. Another DOE document—DOE 

Standard 1189: Integration of Safety into the Design Process—provides guidance on how these 

interim and final safety documents are to be prepared, among other things. For example, it

directs DOE and NNSA to analyze and address fire protection, nuclear criticality, and natural 

hazards, such as earthquakes.12

Results in Brief

According to this standard, the interim safety documents help 

ensure that safety issues are explicitly identified and addressed early in the design phase to 

reduce costly late reversals. Thus, these interim safety documents are to be used to develop the 

UPF’s final safety document, which provides the basis for ensuring that the facility can be 

operated safely with respect to workers, the public, and the environment. According to Order 

413.3B, facilities cannot begin operations until their final safety documents are approved. 

In 2010, members of the Safety Board raised concerns that NNSA was deviating from the 

process established by DOE Order 413.3B and DOE Standard 1189 to develop the UPF’s CD 2 

interim safety document and was, therefore, not ensuring that safety was adequately integrated 

into the UPF’s design. NNSA then took actions to follow the established process, and Safety 

Board staff stated that NNSA’s corrective actions addressed many of their concerns. As of June 

2013, the Safety Board had identified 15 specific safety concerns with the UPF’s design, and 

NNSA has taken or agreed to take actions to address 14 of these concerns. In addition, on 

 

12A nuclear criticality accident occurs when enough fissile material, such as uranium, is brought together to cause a 

sustained nuclear chain reaction. The immediate result of a nuclear criticality accident is the production of an 

uncontrolled and unpredictable radiation source that can be lethal to people who are nearby.
Page 5 GAO-14-79R Nuclear Weapons

August 26, 2013, the Safety Board sent NNSA a letter that identified 12 additional specific 

safety concerns based on the CD 2 interim safety document approved by NNSA in February 

2013. The Safety Board has also raised general concerns with NNSA’s plans to defer the 

installation of some uranium processing capabilities into the UPF at a later date and after the 

UPF is operational. 

The Safety Board Has Identified Concerns with the UPF, and NNSA Has Taken Actions to 

Address Most of Them

Members of the Safety Board have raised concerns that NNSA was deviating from the process 

established by DOE Order 413.3B and DOE Standard 1189 to develop the UPF’s CD 2 interim 

safety document, and therefore not ensuring that safety was adequately integrated into the 

UPF’s design. According to NNSA officials and Safety Board staff, in 2008, when DOE issued 

DOE Standard 1189 on how these documents are to be prepared, the UPF was to be one of the

pilot projects for implementing the new standard. However, in 2009, NNSA decided to expedite 

the UPF by combining the CD 2 and CD 3 milestones, eliminating the development of the 

interim safety document for CD 2, and focusing on the development of alternative safety

documents.13

As of June 2013, the Safety Board also identified 15 specific safety concerns with the UPF’s 

design, and NNSA has taken actions —or has agreed to take actions—to address 14 of these 

concerns.

On several occasions in 2010, members of the Safety Board expressed concerns 

to NNSA regarding its initial decision to cancel the CD 2 interim safety document, and, 

according to NNSA officials, a subsequent UPF independent project review in 2010 

recommended that the project follow the safety document development process established by 

DOE Order 413.3B and DOE Standard 1189. In 2011, NNSA directed the UPF contractor to 

develop the required CD 2 interim safety document, and the contractor completed a revised 

version of the document in September 2012. NNSA approved the CD 2 interim safety document 

in February 2013 with 11 conditions that the UPF contractor must address in subsequent safety 

documents, such as improving the reliability and robustness of venting systems. Safety Board 

staff said that it is not unusual for interim safety documents to be approved with conditions, as 

they can be addressed in subsequent safety documents. See enclosure I for a timeline of the 

development of the UPF’s CD 2 interim safety document. 

14

 

13UPF contractor representatives told us that they were going to develop two alternate safety-related documents—a 

preliminary hazard analysis and a preliminary documented safety analysis —as these documents were DOE’s safety 

requirements prior to the issuance of DOE Standard 1189. 

See enclosure II for a description of the Safety Board’s concerns, NNSA’s actions to 

address the concerns, and the status of the safety concerns. Safety Board staff and NNSA 

officials agreed that none of the 15 concerns should prevent the UPF from reaching CD 2 in 

2015 as scheduled. According to NNSA officials and Safety Board staff, 1 of these concerns—

that the contractor had not developed an adequate corrective action plan to address structural 

engineering issues, among other things, previously identified by the Safety Board—has been 

fully addressed. For 7 other concerns, NNSA has presented evidence that the Safety Board’s 

staff believe is reasonable to fully address the concerns, and the Safety Board is currently in the 

14Of the 15 concerns identified by the Safety Board, NNSA officials said that the agency identified 8 similar concerns 

during an internal review of UPF safety that concluded in January 2012. In addition, NNSA officials told us that the 

agency required the UPF contractor to take corrective action to address 6 of these concerns. 
Page 6 GAO-14-79R Nuclear Weapons

final stages of reviewing the agency’s actions.15 Six other concerns remain open while NNSA is 

completing the corrective actions, which Safety Board officials said they will review once the

actions are completed.

16

On August 26, 2013, the Safety Board sent NNSA a letter that acknowledged the agency’s 

progress in addressing the Safety Board’s previously identified concerns with the UPF. 

However, the Safety Board said that NNSA must continue to improve the effectiveness of the 

UPF’s safety controls and strengthen oversight to ensure planned controls can reliably perform 

their safety functions. In addition, the Safety Board identified 12 additional specific safety 

concerns, such as those related to potential fire and explosion scenarios, based on the CD 2 

interim safety document approved by NNSA in February 2013. See enclosure III for a 

description of these 12 additional concerns. According to NNSA officials, the agency is 

currently reviewing the Safety Board’s letter and preparing a response. Safety Board staff said 

that additional concerns may be raised as UPF completes final design and moves into 

construction.

 For the final concern—about the methodology used to calculate the 

rate at which radioactive material would settle out of the atmosphere in the event of an 

accident—Safety Board staff and NNSA officials said that they are not likely to agree on a path 

to resolution, and NNSA has conducted additional analyses to clarify its position. 

In addition to the specific safety concerns raised above, the Safety Board has also raised 

general concerns with NNSA’s plans to defer the installation of some uranium processing 

capabilities into the UPF at a later date and after the UPF is operational. As discussed above, 

NNSA currently plans to install uranium processing capabilities into the UPF in phases, after the 

building’s exterior, support systems, and some processing capabilities have been completed. 

However, NNSA officials said that the agency does not plan to complete final design and safety 

work for the deferred capabilities until after the initial phase of the UPF is operational, which 

NNSA expects to occur in 2025. Safety Board staff stated that if NNSA encounters any 

challenges while finalizing the design and safety controls for the deferred scope, it will have 

much less flexibility to address them since the building will already have been constructed. 

Currently, NNSA plans to begin and complete subsequent UPF phases between 2030 and 

2036. Safety Board staff stated that this project execution strategy introduces safety-related 

risks that will challenge the project’s ability to integrate safety into the design. For example, at 

an October 2012 public hearing on the UPF, a senior Safety Board staff member noted that 

other DOE projects that have attempted similar complex execution strategies, such as the 

Hanford Waste Treatment Plant, which chose a strategy that allowed construction to begin prior 

to completing design, have had little or no success. In the UPF project, NNSA has decided to 

defer scope for key manufacturing and machining operations and will add them back to UPF 

sometime after it is built, which the senior Safety Board staff member said was similar to the 

Hanford Waste Treatment Plant decision to begin construction before completion of design, and 

magnified the impacts on the plant’s cost and schedule when safety-related issued were 

 

15For example, the Safety Board raised concerns about NNSA’s methodology for analyzing fires resulting from an 

earthquake, and in response, NNSA conducted a new analysis providing additional details on its methodology.

16For example, the Safety Board raised concerns that NNSA’s project office is understaffed to perform effective 

oversight, with many officials sharing project management and technical oversight responsibilities. In response, 

NNSA developed a staffing plan and the project has recently been approved to fill an additional 10 specialist 

positions, such as fire safety engineers and criticality engineers.
Page 7 GAO-14-79R Nuclear Weapons

discovered late in the design process.17 According to NNSA officials and the UPF contractor, 

the UPF project team plans to continue developing the design of the deferred scope capabilities 

to a level of maturity that will ensure all process equipment will fit into the building and the 

proper safety controls for the entire facility are identified. As noted in our July 2013 report, a 

failure to ensure that the UPF contained sufficient space for all the processing equipment 

already resulted in approximately $540 million in additional costs.18

In addition, Safety Board staff stated that performing a major modification to an operating 

nuclear facility can present safety issues if not carefully planned and executed. The UPF 

Federal Project Director, in testimony at the Safety Board’s October 2012 public hearing on the 

UPF, generally agreed with this concern and said that NNSA will need to address a number of 

safety risks during subsequent phases of the project, such as risks to the facility’s fire 

protection, ventilation, and criticality safety systems, as well as risks associated with additional 

construction workers operating in close proximity to hazardous materials and processes.

According to NNSA officials, the UPF project team will need to conduct and document additional 

safety analyses to ensure that construction activities meet DOE’s safety requirements. Safety 

Board officials said that they are monitoring NNSA's efforts to perform the engineering work 

necessary to safely incorporate the deferred scope into the UPF’s design, and may raise 

additional specific safety issues as the design progresses.

 

While we are currently not making any recommendations for congressional consideration or 

agency action, we will continue to review the UPF as required by the National Defense 

Authorization Act for Fiscal Year 2013, and may make recommendations in the future if 

warranted. 

Agency Comments

We provided a draft of this report to NNSA and the Safety Board for review and comment. 

NNSA provided technical comments, which we incorporated into the report as appropriate. 

NNSA’s written comments are reproduced in enclosure IV. On October 3, 2013, we received 

technical comments via email from the Safety Board’s UPF Project Lead, which we incorporated 

into the report as appropriate.

- - - - - 

We are sending copies of this report to the appropriate congressional committees, the Secretary 

of Energy, the Administrator of NNSA, the Chairman of the Safety Board, and other interested 

parties. This report also is available at no charge on the GAO website at http://www.gao.gov.

 

17 According to NNSA’s Associate Administrator for Acquisition and Project Management, the agency’s approach to 

executing the UPF project is distinctly different than any other project within DOE, and is specifically designed to 

reduce the problems experienced with the Hanford Waste Treatment Plant and other DOE and NNSA projects. For 

example, agency officials said that the UPF is the first major project that is implementing DOE Standard 1189 to help 

ensure safety is adequately integrated into design.

18GAO-13-686R. 
Page 8 GAO-14-79R Nuclear Weapons

If you or your staff members have questions concerning this report, please contact me at (202) 

512-3841 or trimbled@gao.gov. Contact points for our Offices of Congressional Relations and 

Public Affairs may be found on the last page of this report. Key contributors to this report were 

Jonathan Gill, Assistant Director; Patrick Bernard; and Will Horton. 

David C. Trimble 

Director, Natural Resources and Environment

Enclosures–4 
Page 9 GAO-14-79R Nuclear Weapons

List of Committees

The Honorable Carl Levin 

Chairman

The Honorable James M. Inhofe

Ranking Member

Committee on Armed Services

United States Senate

The Honorable Dianne Feinstein

Chairwoman

The Honorable Lamar Alexander

Ranking Member

Subcommittee on Energy and Water Development

Committee on Appropriations

United States Senate

The Honorable Howard P. “Buck” McKeon

Chairman

The Honorable Adam Smith

Ranking Member

Committee on Armed Services

House of Representatives

The Honorable Rodney P. Frelinghuysen 

Chairman

The Honorable Marcy Kaptur

Ranking Member 

Subcommittee on Energy and Water Development 

Committee on Appropriations 

House of Representatives 
Page 10 GAO-14-79R Nuclear Weapons

Enclosure I: Timeline of the Development of the Uranium Processing Facility’s Critical 

Decision 2 Interim Safety Document

The National Nuclear Security Administration (NNSA)—a separately organized agency within 

the Department of Energy (DOE)—is required to manage the Uranium Processing Facility (UPF)

project in accordance with DOE Order 413.3B, which establishes the agency’s project 

management principles and process, including protocols for planning and executing a project.19

However, in 2009, NNSA decided to expedite the UPF by combining several CD milestones, 

eliminating the development of the interim safety document for CD 2, and focusing on the 

development of alternative safety documents.

 

This process requires DOE projects to go through five management reviews and approvals as 

they enter each new phase of work, called “critical decisions” (CD). Key interim safety 

documents are to be completed by the contractor and approved by NNSA prior to CD 1, 2, and 

3 milestones, while a final safety document is to be completed and approved prior to CD 4. 

According to Order 413.3B, facilities cannot begin operations until their final safety documents 

are approved.

20 After members of the Defense Nuclear 

Facilities Safety Board—an independent executive branch agency created by Congress to 

assess safety conditions and operations at DOE’s defense nuclear facilities—raised concerns 

that NNSA was deviating from the process established by DOE Order 413.3B, NNSA directed 

the UPF contractor to develop an interim safety document for CD 2. Figure 1 describes the 

timeline by which the required CD 2 interim safety analysis was developed by the UPF 

contractor and reviewed and approved by NNSA. 

 

19U.S. Department of Energy, Program and Project Management for the Acquisition of Capital Assets, DOE O 413.3B 

(Washington, D.C.: Nov. 29, 2010)

20UPF contractor representatives told us that they were going to develop two alternate safety-related documents—a 

preliminary hazard analysis and a preliminary documented safety analysis —as these documents were DOE’s prior 

safety requirements. 
Page 11 GAO-14-79R Nuclear Weapons

Figure 1: Development of the Uranium Processing Facility’s Required CD 2 Interim 

Safety Analysis

Note: DOE’s Office of Health, Safety, and Security, among other things, develops safety policy and conducts 

independent oversight of compliance with DOE’s safety regulations and directives, and enforcement activities. In 

addition, this office conducted an independent review of the UPF’s CD 2 interim safety document. The review 

concurred with the overall conclusions of NNSA’s review, including the decision to approve the document subject to 

additional conditions for proceeding to the next stage of design. See U.S. Department of Energy, Independent 

Oversight Appraisal of the Uranium Processing Facility Safety Basis Preliminary Safety Design Report Process at the 

Y-12 National Security Complex (Washington, D.C.: May 2013).
Page 12 GAO-14-79R Nuclear Weapons

Enclosure II: Safety Concerns Identified by the Defense Nuclear Facilities Safety Board 

with the Uranium Processing Facility as of June 2013 and Actions Taken by the National 

Nuclear Security Administration to Address Those Concerns

Safety 

concern 

number

Safety concern identified by the Defense 

Nuclear Facilities Safety Board (Safety 

Board) with the Uranium Processing 

Facility (UPF) 

Actions taken by the National Nuclear Security 

Administration (NNSA) to address safety concern 

Status of one safety concern where NNSA has completed corrective action

1 The UPF contractor had not developed an 

adequate corrective action plan to address 

structural engineering issues, among other 

things, previously identified by the Safety 

Board. 

According to the Safety Board staff, the UPF contractor 

took appropriate actions—such as identifying the 

controls needed to prevent internal explosions—to 

address the Safety Board’s concern. 

Status of seven safety concerns where the Safety Board’s technical staff believes there is 

reasonable evidence that NNSA has fully addressed these concerns, and the Safety Board is 

currently in the final stages of reviewing the agency’s actions

2 Some potential facility hazards were not 

analyzed, or the frequency or consequences 

of these hazards were assumed to be 

limited.a

 

NNSA, among other things, revised its analyses of the 

UPF’s hazards to address the Safety Board’s concerns 

by, for example, identifying additional safety controls for 

fires. 

3 The project lacks a defensible methodology 

for analyzing fires resulting from an 

earthquake.

NNSA conducted a new analysis providing additional 

details on its methodology.

4 The scenario for accidents involving a 

nuclear criticality is not reasonably 

conservative.b

 

NNSA clarified and revised the amounts of radiation 

that were assumed in its criticality accident scenario, 

and identified an additional safety system to provide 

shielding for workers located near UPF who could be 

exposed to dangerous radiation levels during a criticality 

accident.

5 The analysis of one accident scenario is not 

adequate, as it does not consider all plant 

conditions, such as explosions initiated by a 

fire, that could increase the dispersal of 

hazardous materials.c

 

NNSA provided additional information on, among other 

things, the impact of potential explosions on the fire 

scenario.

6 The UPF project downgraded the ventilation 

system’s seismic rating, meaning that the 

ventilation system will not be designed to 

ensure confinement of hazardous materials 

NNSA upgraded a portion of the ventilation system to 

ensure confinement in the event of an earthquake.
Page 13 GAO-14-79R Nuclear Weapons

Safety 

concern 

number

Safety concern identified by the Defense 

Nuclear Facilities Safety Board (Safety 

Board) with the Uranium Processing 

Facility (UPF) 

Actions taken by the National Nuclear Security 

Administration (NNSA) to address safety concern 

following an earthquake.

7 The UPF project downgraded the seismic 

rating of the facility’s criticality prevention 

controls, meaning that the controls will not 

be designed to reliably survive an 

earthquake and prevent a criticality accident.

NNSA committed to upgrade the seismic rating of 

certain criticality prevention controls.

8 The UPF project team has stated its intent to 

implement Institute of Electrical and 

Electronics Engineers standards for the 

reliability of safety controls used to prevent 

explosions but has not formally detailed this 

approach in the project’s planning 

documents.

NNSA clarified that these standards are included in 

UPF design documents.

Status of six safety concerns where NNSA is completing the corrective action, which Safety 

Board officials said they will review once the actions are completed

9 The UPF project downgraded the seismic 

rating of the criticality accident alarm 

system, meaning that the system will not be 

designed to function during and following an 

earthquake, relying instead on fire alarms to 

initiate evacuation after an earthquake.d

 

NNSA clarified that it expects the contractor to ensure 

worker response to an earthquake would be the same 

as worker response to a criticality alarm. 

10 The structural engineering design is robust, 

but a Safety Board letter raised a technical 

and quality assurance concern associated 

with a computer program, which is in use at 

multiple projects across DOE, including the 

UPF, for analyzing soil-structure interaction. 

NNSA is conducting multiple studies that are intended 

to resolve technical and quality issues with the 

computer program. 

11 The fire suppression system was assumed 

to be sufficient to protect against both large 

and small fires. However, small fires may 

not provide sufficient heat to activate the fire 

suppression system, or may be located in 

gloveboxes—a containment system of 

secured gloves attached to a box that allows 

workers to process nuclear material inside 

the box without risk of contamination—

where the suppression system will not 

provide coverage.

NNSA conducted a new analysis of fire scenarios, 

including, among other things, limiting the quantities of 

hazardous materials in certain gloveboxes. The Safety 

Board staff communicated further concerns with this 

analysis, such as the potential for concurrent fires in 

multiple gloveboxes and NNSA’s failure to demonstrate 

that the fire suppression system will control hazardous 

material releases from smaller fires occurring outside of 

gloveboxes. In response, NNSA committed to 

performing additional analyses to address the Safety 

Board’s concerns.
Page 14 GAO-14-79R Nuclear Weapons

Safety 

concern 

number

Safety concern identified by the Defense 

Nuclear Facilities Safety Board (Safety 

Board) with the Uranium Processing 

Facility (UPF) 

Actions taken by the National Nuclear Security 

Administration (NNSA) to address safety concern 

12 The functional requirements for the fire 

suppression system are incomplete and do 

not address the potential for reactive 

materials contained in gloveboxes getting 

wet in the event of an earthquake, 

potentially causing explosions.

NNSA committed to (1) demonstrating that an explosion 

is not credible in this scenario, or (2) providing 

additional safety controls, such as water-tight containers 

for water-reactive materials.

13 The UPF project office is understaffed for 

providing effective safety oversight of the 

project, with many personnel sharing project 

management and technical oversight 

responsibilities.

NNSA (1) committed to filling seven key management 

positions in 2012; (2) hiring specific subject matter 

experts in 2013-2014, such as in fire protection, 

ventilation, criticality, quality assurance, and 

construction oversight; and, (3) prepared a detailed 

staffing plan. 

According to an NNSA official, as of March 2013 the 

project hired additional safety personnel, and had been 

approved to fill an additional 10 specialist positions, 

such as fire safety engineers and criticality engineers.

14 Several assumptions used in the UPF’s 

engineering models could result in a design 

subject to localized structural failure during 

an earthquake. Such failure could affect the 

operability of safety systems attached to the 

structure. 

NNSA revised the document describing its approach to 

validating the assumptions used, and the Safety Board 

staff is reviewing NNSA’s revisions.

Status of one safety concern where the Safety Board and NNSA are not likely to agree on a path 

to resolution, and NNSA has conducted additional analyses to clarify its position

15 When calculating the rate at which 

radioactive material would settle out of the 

atmosphere onto the surrounding area in the 

event of an accidental release, NNSA 

concluded the material would settle more 

quickly, and thus pose less of a safety 

concern to the public, than could be the 

case using more conservative assumptions.

NNSA conducted a review that validated its analysis. 

Safety Board staff provided NNSA with a written 

explanation of their specific areas of disagreement, and 

NNSA is evaluating this explanation.

Sources: GAO analysis of NNSA and Safety Board data. 

a For example, fires were assumed to be limited to a single process area instead of the full facility because it was 

assumed that fire barriers would prevent their spread.

b A nuclear criticality accident occurs when enough fissile material, such as uranium, is brought together to cause a 

sustained nuclear chain reaction. The immediate result of a nuclear criticality accident is the production of an 

uncontrolled and unpredictable radiation source that can be lethal to people who are nearby. While the UPF will 
Page 15 GAO-14-79R Nuclear Weapons

process the same types of materials that are currently being processed in other facilities at the Y-12 National Security 

Complex, the criticality analysis supporting existing operations assumes higher amounts of resulting radiation than 

are used in the analysis for the UPF.

c According to the Safety Board, the accident of concern is categorized as being beyond the UPF’s design 

requirement. However, DOE Standard 3009: Preparation Guide for U.S. Department of Energy Nonreactor Nuclear 

Facility Documented Safety Analyses directs that these types of accidents be analyzed to provide a perspective of 

the remaining risk associated with operating the facility. 

d According to the Safety Board, the use of the fire alarm does not adequately protect the UPF’s workers because the 

appropriate responses for the two potential accident conditions are inherently different.
Page 16 GAO-14-79R Nuclear Weapons

Enclosure III: Twelve Additional Safety Concerns Identified by the Defense Nuclear 

Facilities Safety Board with the Uranium Processing Facility as of August 2013

On August 26, 2013, the Defense Nuclear Facilities Safety Board (Safety Board) sent the 

National Nuclear Security Administration (NNSA) a letter that acknowledged the agency’s 

progress in addressing the Safety Board’s previously identified concerns (i.e., the 15 specific 

safety concerns identified by the Safety Board in enclosure II) with the design of the UPF. 

However, the letter stated that NNSA must continue to improve the effectiveness of the UPF’s 

safety controls and strengthen oversight to ensure planned controls can reliably perform their 

safety functions. In addition, the Safety Board identified 12 additional specific safety concerns 

with the design of the UPF. According to NNSA officials, the agency is currently reviewing the 

Safety Board’s letter and will provide a report and briefing to the Safety Board by November 22, 

2013, describing NNSA's plan and schedule for addressing the issues. 

The 12 additional UPF-related safety concerns identified by the Safety Board are as follows: 

• Fires in certain process areas: For certain fire scenarios, the fire protection system 

would not actuate or actuation would be delayed and therefore may not prevent a 

significant release of toxicological material. 

• Glovebox fires: Under normal operating conditions, certain gloveboxes—a containment 

system of secured gloves attached to a box that allows workers to process nuclear 

material inside the box without risk of contamination—are provided with an inert gas 

atmosphere that does not allow combustion. However, if the inert environment is lost 

(e.g., due to an earthquake), oxygen intrusion into the glovebox could cause the material 

inside to ignite. Since fire protection sprinklers are located outside of the gloveboxes, 

they cannot be relied upon to protect against such fires. 

• Aircraft crashes: NNSA analyzed aircraft crash scenarios for the main UPF building but 

did not analyze the aircraft crash scenario for ancillary UPF structures, such as the 

loading dock and truck bay. 

• Natural disasters and man-made external events: The UPF structure is designed to 

provide protection against a specific set of natural disasters and man-made external 

events, such as vehicle impacts and wildfires. However, the UPF safety analysis does 

not clearly link the associated functional requirements and performance criteria for the 

UPF structure to the specific accidents. The Safety Board concluded that important 

structural attributes may not be effectively captured and incorporated into the UPF’s 

design. 

• Concurrent releases of multiple hazardous materials: Some fire scenarios in the UPF 

can concurrently release multiple hazardous chemicals. However, the UPF’s safety 

controls are designed to prevent or mitigate hazards based solely on the potential 

release of any single chemical exceeding the applicable thresholds. This could result in 

the need for additional safety controls when the cumulative effects of concurrently 

released chemicals are evaluated.

• Dust explosions: Certain uranium processing activities in gloveboxes can generate 

dusts, which could produce explosions that could seriously injure facility workers. Under 

normal operating conditions, the affected gloveboxes are provided with an inert gas 
Page 17 GAO-14-79R Nuclear Weapons

atmosphere to prevent dust explosions. However, the safety features that provide this 

inert atmosphere could be compromised under certain accident scenarios. 

• Violent chemical reactions: Certain chemical processing activities can result in violent 

chemical reactions that forcefully expel heated chemicals from process vessels. 

However, the UPF project has not identified any credited controls to protect facility 

workers from resulting chemical burns. 

• Combustible materials in certain processing equipment: During a specific uranium 

processing operation, potentially combustible materials might be present. When certain 

processing equipment is heated to its normal operating temperature (approximately 

1400 degrees Celsius), the potentially combustible material could release enough 

energy to rupture the equipment and injure facility workers. The UPF project has not

identified a control to prevent the introduction of potentially combustible material into 

certain processing equipment.

• Steam overpressure in casting furnaces: Potential water intrusion into a furnace that 

casts highly enriched uranium during high-temperature operations can cause a violent 

steam overpressure event that could seriously injure facility workers. The current UPF 

safety strategy has not demonstrated how the credited safety control can prevent the 

water intrusion.

• Hydrogen explosions (1): A hydrogen explosion could occur in the enriched uranium 

purification and metal production process under certain conditions. The current UPF 

safety strategy relies on operator action to prevent a hydrogen explosion but does not 

treat this operator action as a formal safety control, even though it is relied upon to 

prevent an event that could result in serious facility worker injuries. 

• Hydrogen explosions (2): Hydrogen would be released if water reacted with certain 

compounds used in the UPF assembly process area. The UPF safety analysis did not 

evaluate the potential for a hydrogen explosion. 

• Damage to enriched uranium in storage: For earthquake-induced fires, the UPF safety 

analysis assumes that 10 percent of enriched uranium located in the UPF’s storage

racks would be damaged. This 10 percent assumption is based on a series of 

experiments conducted at Los Alamos National Laboratory under controlled laboratory 

conditions. The Safety Board said that the unmitigated earthquake-induced UPF fire 

environment could exhibit conditions that are different than the conditions used in the 

Los Alamos experiments. As such, the Safety Board stated that the UPF project does 

not have adequate data to support its 10 percent damage ratio. 
Page 18 GAO-14-79R Nuclear Weapons

Enclosure IV: Comments from the Department of Energy
Page 19 GAO

-14-79R Nuclear Weapons

(361516)
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